You may have missed it, because this is not a seafood example, but once again FDA has issued a Warning Letter to a firm for alleged situations of species substitution. In this situation, FDA reports finding the following:

• Lamb and Rice Dog Food that did not contain lamb but rather contained bovine
• Grain-free Duck Pet Food that did not contain duck

Again, the take away from this Warning Letter is that species substitution may cause products to be adulterated and misbranded both violations of the Federal Food Drug and Cosmetic Act (the Act).

The products were considered adulterated in that a valuable constituent (lamb or duck depending on the example) had been omitted and, in the case of the lamb, another ingredient had been substituted. Also, the products were considered misbranded in that they were offered for sale under the name of another food or if the labeling is false or misleading.

Species substitution is against the law. These warning letters from FDA confirm what we all already know.